`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`ADVANCED MICRO DEVICES, INC.; and ATI
`TECHNOLOGIES ULC,
`
`Plaintiffs,
`
`v.
`
`TCL INDUSTRIES HOLDINGS CO., LTD.; TCL
`INDUSTRIES HOLDINGS (H.K.) LIMITED;
`TCL ELECTRONICS HOLDINGS LIMITED;
`TCL TECHNOLOGY GROUP CORPORATION;
`TTE CORPORATION; TCL HOLDINGS (BVI)
`LIMITED; TCL KING ELECTRICAL
`APPLIANCES (HUIZHOU) CO. LTD.;
`SHENZHEN TCL NEW TECHNOLOGIES CO.,
`LTD.; TCL MOKA INTERNATIONAL
`LIMITED; TCL SMART DEVICE (VIETNAM)
`CO., LTD; MANUFACTURAS AVANZADAS
`SA DE CV; TCL ELECTRONICS MEXICO, S
`DE RL DE CV; TCL OVERSEAS MARKETING
`LTD.; and REALTEK SEMICONDUCTOR
`CORP.,
`
`Defendants.
`
`
`
`C. A. NO. 2:22-CV-00134
`
`JURY TRIAL DEMANDED
`
`JOINT MOTION FOR EXTENSION OF TIME FOR
`PLAINTIFFS ADVANCED MICRO DEVICES, INC. AND ATI TECHNOLOGIES ULC
`TO COMPLY WITH P. R. 3-1 & 3-2 (INFRINGEMENT CONTENTIONS) AND FOR
`DEFENDANT REALTEK SEMICONDUCTOR CORP. TO COMPLY WITH P. R. 3-3 &
`3-4 (INVALIDITY CONTENTIONS) AND STANDING ORDER REGARDING
`SUBJECT-MATTER ELIGIBILITY CONTENTIONS
`
`Plaintiffs Advanced Micro Devices, Inc. and ATI Technologies ULC (collectively,
`
`“AMD”) and Defendant Realtek Semiconductor Corp. (“Realtek”) respectfully request an
`
`extension of time as follows:
`
`I.
`
`
`
`Case 2:22-cv-00134-JRG-RSP Document 24 Filed 07/01/22 Page 2 of 4 PageID #: 209
`
`On June 14, 2022, the Court set a scheduling conference for this case, which is scheduled
`to occur on July 19, 2022 (Dkt. 18 (“Order”)). Pursuant to the Order, the deadline for AMD to
`
`comply with P.R. 3-1 and 3-2 (Infringement Contentions) is July 5, 2022 and the deadline for
`
`Realtek to comply with P.R. 3-3 and 3-4 (Invalidity Contentions) and to comply with the Standing
`
`Order Regarding Subject-Matter Eligibility Contentions is August 30, 2022.
`
`II.
`
`The parties have conferred and agree to a ten (10) day extension for both deadlines
`
`indicated above. The deadline for AMD to comply with P. R. 3-1 & 3-2 (Infringement Contentions)
`
`would be extended from July 5, 2022 up to and including July 15, 2022. The deadline for Realtek
`
`to comply with P. R. 3-3 & 3-4 (Invalidity Contentions) and to comply with the Standing Order
`
`Regarding Subject-Matter Eligibility Contentions would be extended from August 30, 2022 up to
`
`and including September 9, 2022.
`
`Current Deadline New Deadline
`July 5, 2022
`July 15, 2022
`
`August 30, 2022
`
`August 30, 2022
`
`Description
`Comply with P.R. 3-1 & 3-2 (Infringement
`Contentions)
`September 9, 2022 Comply with P.R. 3-3 & 3-4
`Contentions)
`September 9, 2022 Comply with Standing Order Regarding Subject-
`Matter Eligibility Contentions
`
`
`(Invalidity
`
`III.
`
`The Parties do not file this Joint Motion for the purpose of delay, but rather to allow the
`
`Parties to adequately address the issues associated with the pending Contentions and in order that
`
`justice be done.
`
`
`
`2
`
`
`
`Case 2:22-cv-00134-JRG-RSP Document 24 Filed 07/01/22 Page 3 of 4 PageID #: 210
`
`Dated: July 1, 2022
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`By: /s/ Eric H. Findlay
`Eric H. Findlay
`State Bar No. 00789886
`Brian Craft
`State Bar No. 04972020
`FINDLAY CRAFT, P.C.
`102 N. College Ave. Suite 900
`Tyler, Texas 75702
`Tel: (903) 534-1100
`Fax: (903) 534-1137
`Email: efindlay@findlaycraft.com
`Email: bcraft@findlaycraft.com
`
`Michael T. Renaud
`James M. Wodarski
`Michael J. McNamara
`Adam S. Rizk
`William Meunier
`Marguerite McConihe
`Matthew A. Karambelas
`Catherine Xu
`Tianyi Tan
`MINTZ LEVIN COHN FERRIS
` GLOVSKY AND POPEO PC
`One Financial Center
`Boston, MA 02111
`617-542-6000
`
`Attorneys for Plaintiffs
`Advanced Micro Devices, Inc. and ATI
`Technologies ULC
`
`
`
`By: /s/ J. Mark Mann
`J. Mark Mann
`State Bar No. 12926150
`Mark@TheMannFirm.com
`G. Blake Thompson
`State Bar No. 24042033
`Blake@TheMannFirm.com
`MANN | TINDEL | THOMPSON
`201 E. Howard St.
`Henderson, Texas 75654
`
`3
`
`
`
`
`
`Case 2:22-cv-00134-JRG-RSP Document 24 Filed 07/01/22 Page 4 of 4 PageID #: 211
`
`(903) 657-8540
`(903) 657-6003 (fax)
`
`Attorneys for Defendant Realtek Semiconductor
`Corp.
`
`
`
`CERTIFICATE OF SERVICE
`
` The undersigned hereby certifies that on July 1, 2022, all counsel of record who are
`
`
`
`deemed to have consented to electronic service are being served with a copy of this document via
`
`the Court's CM/ECF system per Local Rule CV-5(a)(3).
`
`
`
`
`
`/s/ Eric H. Findlay
` Eric H. Findlay
`
`
`
`CERTIFICATE OF CONFERENCE
`
`The undersigned hereby certifies that all counsel of record have met and conferred in
`
`accordance with Local Rule CV-7(h) and this joint motion is unopposed.
`
`
`
`/s/ Eric H. Findlay
` Eric H. Findlay
`
`
`
`
`
`4
`
`
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